I would like to clarify the difference between refinance and renewal under HMDA. Under our renewals we can payoff a dwelling secured loan by having the client sign a new note which indicates a new rate and term. The same account number is used and we continue to use the dwelling as collateral. Is this in fact the same as a refinance and should be reported under HMDA?

It depends - all of our renewal notes have language on them that says "this note renews and does not satisfy a note to lender...". We do not report these for HMDA. If you have similar language, I would consider the renewal note to be a modification and not reportable. If not, I would consider it a refi. The account number used has no impact on the decision.

FWIW I agree with hmdagal.